Hotel Superhero — Privacy Policy

Scope

This Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hard copy.

This Privacy Policy describes the ways in which Superhero Tech Private Limited may collect, use, and disclose information about you through our websites, platform, marketing activities, publications, social media properties, and other online services that link to this Policy (collectively, the “Online Services”), along with the choices you make about the way your information is collected. By using the Online Services or subscribing to our Services (as defined in our Terms), you consent to the processing of your information as set forth in this Privacy Policy, now and as amended by us.

This Policy does not cover information regarding data collected from our Users in the course of providing the Services — for example, hotel property data, OTA credentials, guest review data, and WhatsApp campaign data processed through the Hotel Superhero platform. Such data processing is governed by our Terms, in particular Clause 5 (User Content) and Clause 6 (Use of Services), available at https://hotelsuperhero.com/terms.

If, at any time, a User provides data or other information about someone other than himself, herself or itself, the User warrants that they have that person's consent to provide such information for the purpose specified.

Information Collection

We collect information that you provide when you: access or use the Hotel Superhero platform at https://hotelsuperhero.com; subscribe to our Revenue Management Service (“RMS Service”) or Property Management System (“PMS Service”) as described in Schedule 1 of our Terms; interact with our website via web-forms or chatbots; engage with us on social media; apply for employment; participate in surveys; register for events or webinars; sign up for electronic newsletters; download reports; or contact us with questions, comments, or requests.

The information you provide may include, but is not limited to: your name, photograph, and contact details (physical address, email address, phone number); username, password, and other account registration information; employment application information; property information provided in connection with the RMS Service or PMS Service (such as room inventory, OTA credentials, and Google Business account details as required under Clause 2(g)(iv) and Clause 6(d) of our Terms); and any other information you choose to share.

We and our service providers collect information from three main categories:

• Direct Interactions: Data from your use of and interaction with us through the Hotel Superhero platform, social media channels, account creation, subscription sign-up, chatbot interactions, or sales inquiries and transactions.
• Publicly Available Data / Data from Third Parties: Data from non-Hotel Superhero websites you interact with, data you have made publicly available (such as social media posts), or data provided by third parties including OTA platforms (MakeMyTrip, Goibibo, Booking.com, Agoda, and others), marketing opt-in lists, or data aggregators.
• Automated Interactions: Data from technologies such as electronic communication protocols, cookies, or IP addresses.

We may automatically collect technical information from your device over time and across different websites when you use the Online Services, such as your IP address, browser type, operating system, pages viewed, and search terms entered. This allows us to recognise you, personalise your experience, improve our Services, and provide you with relevant advertisements (“Targeted Advertisements”).

We and our service providers may collect and store this information using “cookies” — small text files saved on your device — or similar technologies.

Information Use

We do not collect Sensitive Personal Data (meaning, under EEA standards, data regarding an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life).

We, and our affiliates and subsidiaries, may use the information collected for a number of purposes, including, but not limited to:

• Providing you with the Services or information you request, including the RMS Service (AI-powered dynamic pricing, OTA management, guest review management, Google and social media management, and WhatsApp marketing) and the PMS Service, as defined in Clause 1(e) of our Terms.
• Supporting your customer relationship with us, including assigning a dedicated Revenue Expert, conducting fortnightly strategy reviews (as provided under Clause 2(d)(i) of our Terms), and notifying you of service updates or changes.
• Onboarding your property onto the Hotel Superhero platform, including AI pricing configuration, OTA listing optimisation, and Google/social page setup (as provided under Clause 2(d)(ii) of our Terms).
• Processing an employment application or verifying your identity.
• Providing required notices and information about the Online Services.
• Delivering marketing communications, promotional materials, or Targeted Advertisements.
• Improving the Online Services and our products, including tailoring content to user needs.
• Generating and analysing statistics about use of the Online Services.
• Detecting, preventing, and responding to fraud, intellectual property infringement, violations of law, or other misuse of the Online Services.

We may also combine or aggregate any of the information we collect through the Online Services or elsewhere (e.g., via telephone, email, social media, or public events) for any of these purposes.

Information Disclosure

We may disclose the information we collect from you through the Online Services to:

• Our affiliates and subsidiaries, including Treebo Hospitality Ventures Private Limited.
• Service providers and suppliers who work on our behalf and have agreed to keep information confidential and use it solely to carry out services for us.
• OTA platforms, Google, Facebook, Instagram, WhatsApp Business API, and other third-party platforms to the extent necessary to deliver the RMS Service or PMS Service under our Terms — specifically in connection with account management as described in Clause 6(d) and the platform-specific activities described in Clause 8(c)–(g) of our Terms.
• Government or regulatory authorities as required by law, including to comply with a subpoena, court order, or reporting obligation.
• Third parties as necessary to protect our rights, the integrity of the Online Services, or the safety of others, or to detect, prevent, or respond to fraud or misuse.
• Advisors and other third parties to the extent reasonably necessary to proceed with a merger, acquisition, or sale of all or a portion of our assets.

We will not sell, rent, or lease information that can personally identify you to others, except as described in this Privacy Policy.

The Online Services may also contain links to third-party websites and applications for your convenience and information, including OTA platforms, Google, Facebook, and Instagram. Hotel Superhero does not control said third-party websites or their privacy practices. You acknowledge and agree that we are not responsible for the collection and use of your information by third-party websites that are not under our control, and such information is not governed by this Privacy Policy. Please refer to Clause 6(c) of our Terms regarding third-party tools accessible through the platform.

Information Processing

Information collected through the Online Services may be transferred to our affiliates, subsidiaries, and service providers for purposes that include data consolidation, storage, and simplified customer information management. By using the Online Services, you consent to such transfer and processing.

Legal Basis for Processing Personal Information

Our legal basis for processing your personal information for the purposes stated above will depend on the personal information concerned and the context in which we collect it.

Superhero Tech Private Limited collects and processes personal information where:

• You have provided your consent for us to do so.
• We need the personal information to perform services under a contract with you — in particular, to deliver the RMS Service or PMS Service as described in Schedule 1 of our Terms.
• The processing is in our legitimate interests — for example, to improve our AI pricing engine, OTA management tools, and service delivery capabilities — and not overridden by your data protection rights and freedoms.
• We have a legal obligation to collect or retain personal information from you.

Information Security

We strive to maintain reasonable administrative, technical, and physical safeguards designed to protect the information collected by the Online Services. However, no information system is 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Online Services over networks that we do not control, including the Internet and wireless networks. Please also refer to Clause 10(b) of our Terms regarding our confidentiality obligations in the course of delivering our Services.

Information Retention

We will retain your information for as long as your account or Subscription Term is active or as needed to provide our Services. We shall retain and use the information collected by us as necessary to comply with our legal obligations, resolve disputes, or for other legitimate business purposes.

Upon termination or expiry of the RMS Service or PMS Service (as provided in Clause 9 of our Terms), we will handle your data as follows: (i) we will cease active management activities on your OTA listings and social/digital pages within five (5) business days of termination; (ii) upon written request, we will return or transfer access credentials to OTA platforms and Google/social accounts created by us on your behalf, subject to settlement of all outstanding dues; and (iii) we will provide a final performance summary report within ten (10) business days of termination. AI pricing configurations, OTA listing content, review response templates, and WhatsApp campaign content created by the Company remain the intellectual property of the Company as provided in Clause 9(f)(iii) of our Terms.

If you cancel, deactivate, or unsubscribe your account or contract with us, we are not under any obligation to retain your information beyond what is required by applicable law.

Children's Information

The Online Services are not directed to, nor do we knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us at the contact information listed below.

Geographic Data Transfers

We store your data within the permitted geographical boundary. All data collected in connection with the Hotel Superhero platform is stored in India. In all instances, we ensure adequate measures are in place so that transfers of personal information are in accordance with applicable Indian laws, including the Information Technology Act, 2000 and rules made thereunder. Any disputes arising in connection with data processing under our Terms shall be subject to the governing law and jurisdiction provisions of Clause 10(a) of our Terms (Bangalore, India).

Changes to This Privacy Policy

Please refer to this Policy often for the latest information. Superhero Tech Private Limited keeps this Privacy Policy under review and has the right to revise it at any time. Any such revisions will be effective immediately upon posting and we will notify you by posting a new Privacy Policy on this page and updating the revision date below. If we make any revisions that materially change the ways in which we use or disclose information previously collected from you, we will give you the opportunity to consent to such changes prior to applying them to that previously collected information. Material changes to our Terms that affect data processing will similarly be communicated with reasonable prior notice, in accordance with Clause 2(d)(v) of our Terms.

User Rights

We want to ensure that you are fully aware of your rights in relation to the information we hold about you. You have the following rights:

• Access: The right to access the information we hold about you and to obtain details of the processing, including a list of all third parties that have your Personal Information through us.
• Rectification: The right to seek correction, update, or modification of the information available with us, to ensure accuracy.
• Cancellation/Erasure: The right to seek cancellation or erasure, free of charge, of your personal data when it is inadequate, excessive, or unnecessary, subject to lawful processing requirements and our retention obligations under Clause 9 of our Terms.
• Objection: The right to withdraw your consent to our continued processing of information, at any time, subject to any legitimate reason for continued processing in certain circumstances.
• Portability: The right to receive your personal data in a machine-readable format to be provided to another service provider.

Contact Us

If you have any questions about this Privacy Policy, our use of your information, complaints relating to personal information processing, or if you wish to exercise any of your rights, please contact us at:

Email: support@hotelsuperhero.com

Address: Superhero Tech Private Limited, HustleHub Tech Park, HSR Layout, Bengaluru.

For questions specifically relating to our Terms and Conditions of Subscription Services, including data processing in the course of delivering the RMS Service or PMS Service, please also refer to Clause 11 of our Terms.